This Data Protection Notice (“Notice”) sets out the basis which *SCAPE (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA 

1. As used in this Notice:
   • “customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
   • “personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, identification numbers such as NRIC/FIN (partial), work permit, residential address, email address, telephone number, nationality, gender, date of birth, marital status, employment information, financial information and social media information.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

 

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
5. We may collect and use your personal data for any or all of the following purposes:
   • performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
   • verifying your identity;
   • responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
   • managing your relationship with us;
   • processing payment or credit transactions when you purchase goods and services from us
   • for verification and record of your personal particulars including comparing it with information from other sources and using the information to communicate with you
   • to conduct statistical analysis of the users of our sites including but not limited to, the number of users, the frequency of use, profile of users and using such analysis for our business plans, the enhancement of our products and services, targeted advertisements and conveying such information in broad terms (but not information in relation to specific individuals to third partiers who have or propose to have business dealings with us.
   • complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
   • for purposes related to security and safe mall management practices.
   • sign ups for programmes and participating in marketing campaigns.
   • any other purposes for which you have provided the information;

6. We may disclose your personal data:
   • where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
   • to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.
   • to authorities enforced by law

7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter.

 

WITHDRAWING YOUR CONSENT

8. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
9. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within seven (7) business days of receiving it.
10. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

 

ACCESS TO AND CORRECTION OF PERSONAL DATA

11. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
12. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
13. We will respond to your request as soon as reasonably possible. In general, our response will be within seven (7) business days. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

 

PROTECTION OF PERSONAL DATA

14. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, disclosing personal data both internally and to our authorised third party service providers only on a basis related to events/programmes offered by us, and usage of cloud-based virtual desktops with 2fa authentication.

15. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

16. You must remember to log off from your account and close the browser window after use so that no unauthorised party can have access. You are responsible for the safe-keeping of your password. We will not be responsible for any breach caused by your own self-negligence and you agree that you will not hold us responsible for any losses or damage incurred by you whatsoever caused by your non-compliance to any of the foregoing.

 

ACCURACY OF PERSONAL DATA

17. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

 

RETENTION OF PERSONAL DATA

18. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected and beyond for purposes of marketing communications and/or data analysing, or as required or permitted by applicable laws.

 

DATA PROTECTION OFFICER

19. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Email Address  : dpo@scape.sg

 

EFFECT OF NOTICE AND CHANGES TO NOTICE

20. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
21. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Last updated   :           26/07/2021